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SILVERXSTARCOMMUNCATONS
February 22, 2013
Marlene H. Dortch, Secretary
Office of the Secretary
Federal Communications Commission
445 12 th Street SW, Suite TW-A325
Washington, DC 20035
Re:ertification of CPNI Filing, due March 1, 2013
EB Docket 06-36
Dear Ms. Dortch:
Silver Star hereby submits its annual compliance certification for the year ending
December 31, 2012 and for those entities listed on Attachment "A" of said Certification,
pursuant to Section 64.2009(e) of the Commission's Rules. Included is a statement of
how Silver Star's and its Affiliates' operating procedures ensure compliance with the
Rules, an explanation of actions taken against data brokers, and a summary of customer
complaints received in the past year concerning the unauthorized release of Customer
Proprietary Network Information (CPNI).
Please direct any questions about this filing to me at the phone number below or
by email to: [email protected] .
Michelle Motzkus
Legal & Regulatory Administrator
307-883-6690
PO Box 226
Freedom, WY 831
307.883.2411 Phone
307.883.2575ax
877.883.2411oll Fr
www.silverstar.corn eb
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Ann ual 47 C.F.R. § 64.2009(e) CPN I Certification
EB Docket 06-36
Annual 64.2009(e) CPN I Certification for 20 12
Date filed: February 22, 20 13
Na me of com pany(s) cov ered by this certification: Silver Star and A ffiliates (see Attachm ent "A")
Form 499 Filer ID : See Attachment A
Nam e of signatory: Ron B. McC ue
Title of signatory: President and C hief Operating O fficer
I, Ron B . McC ue, certify that I am an officer of the company nam ed above, and acting as an agent ofthe company, that I have personal knowledge that the company has established operating procedures that areadequate to ensure comp liance with the Comm ission's CPN I rules. See 47 C.F.R. § 64.2001 et seq.
Attached to this certif ication is an accomp anying statement explaining how the com pany's proceduresensure that the compan y is in compliance w ith the requiremen ts set forth in section 64.2001 et seq. of theCom mission's rules.
The com pany has n ot taken any actions against data brokers in the past year (i.e., proceedingsinstituted or petitions filed either state comm issions, the court system , or at the Comm ission against databrokers).
The com pany has received no customer com plaints in the past year concerning the unauthorizedrelease of C PNI.
Signed
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Attachment A
Silver Star Company/Affiliate Names an d 499 Filer IDs for 2012 CP NI Certification
C o m p a n y N a m e 499 Fi ler ID
Silver Star Telephone Com pany, Inc.803382
Columbine Telephone Company, Inc. 804096
Gold Star Com municat ions, LLC 825853
M ountain Land C omm unications, LLC 818686Millennium Networks, LLC 829237
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Attachment B
Statement Concerning Procedures Ensuring Compliance with CPNI Rules
The operating procedures of Silver Star (the "Com pany") ensure that the Com pany com plies withPart 64, section 2001 et.seq. of the FCC rules governing the use of CPNI.
The Co mp any has established a system by w hich the status of a customer's approval for the use ofCPNI can be clearly established prior to the use of CPNI. The C ompan y relies on the involvement of itssupervisor/management to ensure that no use of C PNI is m ade without review of applicable rules and law.
The Co mpany trains its personnel regarding when they are authorized to use CPN I, as well as when
they are not authorized to use C PNI. Personnel m ust sign a verification form stating they have com pleted
training and understand that any infraction of the CP NI procedures can result in disciplinary action being
taken against them.
The C ompan y has an express disciplinary process in place for personnel who create or areinvolved in an infraction of the CPNI rules and the Comp any's CPNI O perating Procedures.
The C ompany maintains records of its own sales and m arketing campaigns via a log. These recordsinclude a description of each cam paign, the specific CPN I used in the campaign, and the products andservices that were offered as a part of the campaign. The C ompan y has a supervisory review process for alloutbound m arketing. The marketing campaign log requires a supervisor to review, sign and date the log.These records are maintained for a minimu m of one year.
The Com pany m aintains records of customer approval for the use of CPN I that include a copy of thenotice and the customer's "opt-out" w ritten notification. These records are m aintained for a minimu m of oneyear.
The C omp any requires that customers be authenticated at the beginning of all customer initiatedcalls, online transactions, or in-store visit. In store visits require a valid photo ID.
The Com pany m aintains a log of unauthorized use of CPNI, wh ere law enforcement is required to be
notified. This includes the date of discovery, notification to law enforcem ent, description of the breach,circumstances of the breach and a sup ervisor's signature and date. This log is maintained for a minim um o f
two years.